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June 12th, 2025
Texas is Second State (After Utah) to Enact “App Store Accountability Act,” Targeting Mobile App Stores
In March 2025, Utah enacted SB 142, the "App Store Accountability Act," followed by Texas Governor Abbott signing SB 2420 with the same title in late May 2025. Both laws impose new parental consent and age verification requirements on app store operators distributing apps on mobile devices, with Utah's law taking effect May 6, 2026, and Texas's law taking effect January 1, 2026.
These laws establish certain compliance requirements for both mobile app distribution platforms and third-party app developers, which includes:
Age Verification Requirements: App Store operators must use commercially reasonable methods to verify user ages and categorize users into specific age groups when users create accounts. The mandatory age categories are as follows:
- Child (12 years old and under)
- Younger Teenager (13–15 years old)
- Older Teenager (16–17 years old)
- Adult (18+)
Parental Consent: App Store operators must obtain verifiable parental consent from a minor's parent or guardian before permitting users under the age of 18 to download apps, purchase apps, or make in-app purchases.
App Developer Requirements: In addition, App Store operators must share age and consent data with third-party app developers, who in turn have obligations to implement that data accordingly (e.g., block minor users from downloading apps and making purchases if no parental consent was properly obtained) and safeguard such data. In addition, app developers must notify App Store operators of "significant changes" to their applications, including changes to personal data collection practices, app ratings, monetization mechanics, advertisements, and other material functionality changes.
Terms of Service Restrictions: Further, App Store operators and third-party app developers are prohibited from enforcing terms of service against minor users except where proper parental consent has been obtained for covered activities.
In addition, non-compliance carries substantial penalties. Utah permits fines up to $1,000 per violation plus private consumer lawsuits, while Texas allows private rights of action with potential injunctive relief, actual and punitive damages, and attorney fees, and designates violations as deceptive trade practices under Texas law.
These changes affect app stores serving Texas and Utah residents and will require substantial technical infrastructure updates for App Store operators and third-party app developers alike.
Read the Frankfurt Kurnit Technology Law blog for more developments.
If you have questions about the court ruling or about other interactive entertainment issues, please contact S. Gregory Boyd at (212) 826 5581 or gboyd@fkks.com, Sean F. Kane at (212) 705-4845 or skane@fkks.com, Emma C. Smizer at (310) 579-9570 or esmizer@fkks.com or any other member of the Frankfurt Kurnit Interactive Entertainment Group.
Other Entertainment Law Alerts
New California Law Restricts Use of Words “Purchase” & “Buy” for Licensed Digital Goods
On September 24, Gov. Gavin Newsom signed into law AB 2426 (effective Jan. 1, 2025), a consumer protection bill that expands the scope of false advertising in California. In short, AB 2426 prohibits interactive entertainment and digital media companies from using words like “buy,” “purchase,” or any other words that indicate unrestricted ownership over digital goods. Violators may face injunctions and civil penalties imposed by California regulators or civil claims from individuals with proper standing. Read more.
October 3 2024
Major Studios and Guilds Forge New COVID-19 Production Safety Agreement
As production begins to restart in an ever changing COVID-19 landscape, The Alliance of Motion Picture and Television Producers (AMPTP) and other major studios announced an important deal with the DGA, IATSE, Teamsters, Basic Crafts, and SAG-AFTRA -- meant to ensure the safety and security of their members during the upcoming months. Read more.
September 22 2020
New York City Reopens for Film and Television Production
On July 17, 2020 NYC Mayor Bill de Blasio announced that, with the City entering Phase Four of Reopening on Monday July 20th, 2020, film and television production in the City can restart again in earnest. Read more.
July 21 2020
